According to the complaint, the Logsdons rented a mobile home pad at Sunny Shores Mobile Park. They say Jalali, who was the manager of the mobile home park at the time, agreed to remove old tie-downs left behind by a previous tenant. The Logsdons say the tie-downs were in the backyard and buried deeply in the ground with a small portion sticking up. The part left above ground was painted black.

After moving in, the Logsdons say they continually asked Jalali to remove the tie-downs. Despite being promised by the manager that they would be removed, the couple says the stakes remained on their property.

The Logsdons claim that one evening in September 2008 Dale was taking out the trash and tripped over one of the tie-downs. Dale says he hurt his shoulder, neck, back and ankle in the fall – injuries, he says, make him unable to work.

The Logsdons are suing Jalali, now the owner of Sunny Shores Mobile Park, and his company, Lakeshore Estates Mobile Home Park for breach of oral contract and negligence. They are asking for a judgment of $1 million to compensate for lost wages, medical expenses and attorney fees.